FCC Invites Comments on Amateur Radio Restructuring Plans

NEWINGTON, CT, Mar 24, 2004--The FCC is seeking comment on three plans--including ARRL's call for a new beginner's license and code-free HF access--that would reshape the Amateur Service licensing structure. Each Petition for Rule Making responds to actions taken at World Radiocommunication Conference 2003 (WRC-03) last summer that made changes to Article 25 of the international Radio Regulations. While differing substantially in some other aspects, the three restructuring petitions call for modifications at Amateur Radio's entry level and for a three-tiered license system. One petition goes beyond licensing structure to recommend additional changes to amateur testing and HF digital privileges. A fourth petition put on public notice today focuses solely on the Morse requirement. Designated as RM-10867 through RM-10870, all four petitions are available via the FCC's Electronic Comment Filing System. Comments are due by Friday, April 23.

ARRL--the National Association for Amateur Radio (RM-10867)

Filed by the ARRL, this petition asks the FCC to create a new entry-level Amateur Radio license that would include HF phone privileges without requiring a Morse code test. The League also has proposed consolidating all current licensees into three classes, retaining the Element 1 (5 WPM) Morse code requirement only for the highest class.

An earlier news report "ARRL to Propose New Entry-Level License, Code-Free HF Access," outlines the League's proposals and their rationale. The ARRL has addressed frequently asked questions (FAQs) concerning this proposal on its Web site.

In general, the ARRL proposes a new entry-level license class--being called "Novice" for now--that would require a 25-question written exam. It would offer limited HF CW/data and phone/image privileges on 80, 40, 15 and 10 meters plus certain VHF and UHF privileges. The League plan also would consolidate Technician, Tech Plus (Technician with Element 1 credit) and General class licensees into a new General license that no longer would require a Morse examination. Current Technician and Tech Plus license holders automatically would gain current General class privileges without additional testing. Applicants for Extra would still have to pass a 5 WPM Morse code examination, but the General and Extra written exams would stay the same.

The overall proposed ARRL license restructuring plan would incorporate the "Novice refarming" plan the League put forth nearly two years ago in a Petition for Rule Making (RM-10413). The FCC has invited comments on the ARRL proposal in WT Docket 04-140.

Radio Amateur Foundation (RM-10868)

In its wide-ranging, 59-page petition and, "an unincorporated grassroots organization" calling itself the Radio Amateur Foundation (RAF) has asked the FCC to modify the Technician ticket "to allow restricted high-frequency telephony, data, image and CW privileges." The group also proposes retaining the 5 WPM Morse requirement for General and Amateur Extra applicants, upgrading Advanced class holders to Extra and all Novice licensees to Technician.

The Radio Amateur Foundation said it believes modifying the existing Technician class license "is the most sensible route for both the Commission and the Amateur Service." The RAF added that it sees no need to change licensing requirements for General or Amateur Extra class applicants.

Taking a staunch pro-Morse code stance, the RAF says "it is commonly accepted that an amateur whom [sic] is proficient in radiotelegraphy has a distinct advantage over other amateurs who are not likewise proficient in this simple communications method." Morse code "doesn't prevent the 'best and brightest' from entering the Amateur Service," the group maintains in its petition.

Among other changes, the RAF proposes scrapping the existing Amateur Radio question pools and starting over from scratch to "return to a testing procedure that is in compliance with international and federal law" and to require applicants to learn rather than memorize the examination material. It also wants to keep the question pools out of the public domain and require a 10-day waiting period before retesting. In addition, it would permit only General or Amateur Extra licensees or Technicians licensed more than two years to request vanity call signs.

The RAF also has asked the Commission to relax emission restrictions to permit digital experimentation from 29.0 to 29.3 MHz at up to 15 kHz in bandwidth. The group says it "can envision the evolution of a network infrastructure that is not unlike today's popular Internet," yet designed around Amateur Radio needs and constraints.

The Radio Amateur Foundation says its "thoughtful blueprint" for the future of ham radio in the US also lays down "the groundwork for maintaining the integrity and culture of Amateur Radio itself, while simultaneously providing for progressive new services on underutilized amateur spectrum," while providing "ample motivation for newcomers."

Ronald D. Lowrance (RM-10869)

In his two-page petition, Ronald D. Lowrance, K4SX, asks the FCC to retain the 5 WPM Morse code requirement for General class applicants and to raise the Morse requirement from 5 WPM to 13 WPM for Amateur Extra class applicants. Lowrance would make no change in the Technician class licensing requirements.

Calling Morse code "a key component of communication for our community service responsibilities under and within Department of Homeland Security," Lowrance says Morse code would be "the most reliable mode of communication" in an emergency and should be retained as a licensing requirement.

"The amateur's ability to transmit messages during difficult atmospheric and manmade conditions will be critical when other operators [are] not capable of transmitting and copying CW when voice and digital modes fail," he asserts in his petition.

An FCC staff member said Lowrance's petition, filed last September, apparently was not grouped with 14 earlier Morse-related petitions because it arrived too late. When putting them on public notice, the FCC prefers to group service-related petitions.

National Conference of Volunteer Examiner Coordinators (RM-10870)

The National Conference of Volunteer Examiner Coordinators (NCVEC) has asked the FCC in its petition to establish a new entry-level license it would call the Communicator class. Saying that the current Technician entry-level examination is "overly complex," the NCVEC says it wants to get back to something more along the lines of the earlier Novice license--no longer offered, although some 32,000 Novice licensees remain in the FCC database.

The NCVEC's license restructuring plan also would altogether eliminate the Morse code testing requirement, something it already petitioned the FCC for last fall in RM-10787. Eliminating Morse code as a licensing requirement, the NCVEC said, would "remove one barrier to obtaining an Amateur Radio license," while a new entry-level license "will ease another."

"We believe the need for demonstrating this skill has long since passed, and that those who choose to explore this mode will do so of their own free will," NCVEC said.

The NCVEC's petition would upgrade all Novice licensees to Communicator class. Paralleling ARRL's petition, the NCVEC would further upgrade all existing Technician and Tech Plus (Technician with Element 1 credit) licensees to General and all Advanced class licensees to Amateur Extra without further testing.

Once the Morse requirement goes away, NCVEC said in its filing, "there will be no effective difference between the Technician and General class licenses."

As proposed by the NCVEC, the new Communicator class ticket would include a power limit of 100 W on bands below 24 MHz and 50 W on all frequencies above 24 MHz. Communicator licensees would have to use commercially manufactured equipment (or gear built from a commercial kit). It would permit both voice and digital modes on 80, 40, 15 and 10 meters plus VHF and UHF up to 70 cm. The test would be 20 questions, and applicants would be required to "obtain and read a copy of the current FCC Part 97 rules and to have this information available at all times."

As the ARRL did in its "Novice refarming" proposal, the NCVEC petition calls for some adjustments to existing HF assignments on 80, 40 and 15 meters--primarily to provide additional phone subband space for General and Extra licensees.

While the ARRL-VEC is a member of the NCVEC, ARRL's representative abstained from voting on whether to go forward with a license restructuring petition at the organization's annual meeting last summer.

Commenting on these Petitions

Interested parties may comment on these petitions by Friday, April 23 via the FCC Electronic Comment Filing System (ECFS). Click on "Submit a filing." To view filed comments, click on "Search for filed comments." In both cases enter the appropriate RM number in the "Proceeding" field, with "RM" in capital letters and including the hyphen. Commenters should include their full name, US Postal Service mailing address and appropriate RM number when completing the transmittal screen.

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